Portugal: New Unique ID Number (ATCUD) Delayed Until 2022

Gabriel Pezzato
October 27, 2020

Portuguese authorities recently published the long awaited regulation on unique ID number (ATCUD), in preparation for the entry into force of this requirement on 1 January 2021. Even though this effectively meant that a significant piece in the puzzle had now become available to the public, the Portuguese tax authority has postponed the requirement until 2022. Introduced as a concept in 2019, the ATCUD will instead be mandatory from 1 January 2022 according to the new Ministerial Order 412/2020-XXII. Consequently, the previous January 2021-deadline established by Ordinance 195/2020 has been postponed for one more year.

Validation codes

Other specifications implemented by Ordinance 195/2020 are however still valid. Companies issuing invoices under Portuguese law must communicate the document series used in the invoices to the Portuguese tax authorities, prior to it being applied to the invoice. Once this has been done, the tax authority issues a validation code for each reported series.

This validation code is later used as part of the ATCUD. The ATCUD includes the validation code of the series and a sequential number within the series in the format “ATCUD:Validation Code-Sequential number”. The ATCUD must be included in all invoices immediately before the QR code and be readable on every page of the invoice.

To obtain a validation code, taxpayers must provide the following data to the Portuguese tax authority:  

  1. The identification of the document series
  2. The type of document, following the document types established in the SAF-T (PT) data structure
  3. The starting number of the sequential number used within the series
  4. The date when the taxpayer is expected to start using the series to which a validation code is required

Once this information has been successfully communicated, the tax authority creates a validation code with a minimum size of eight characters.

Also, according to Ordinance 195/2020, the sequential number that is also part of the ATCUD is a reference obtained from a specific field of the Portuguese version of the SAF-T file.

The new Ministerial Order 412/2020-XXII also states that the tax authority must allow taxpayers to communicate the series to obtain a validation code from the second half of 2021 so they can prepare and adjust to comply with the new requirement. The process of how to communicate the data to, and retrieve the validation code from the tax authority, has yet to be published.

As opposed to the recent change regarding the entry into force of the ATCUD, the enforcement of the QR code has been confirmed for 1 January 2021. Technical specifications relating to the QR code are available on the tax authority’s website.

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Gabriel Pezzato

Gabriel Pezzato is a Senior Regulatory Counsel at Sovos. Based in Stockholm and originally from Brazil, Gabriel’s background is in tax, corporate and administrative law. Gabriel earned a Law degree and a specialization degree in Tax Law in his home country and has a master’s degree in International and European Tax Law from Uppsala University (Sweden).
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